Circuit Court of Appeals, Fifth Circuit.https://leagle.com/images/logo.png
February 18, 1946.
February 18, 1946.
Attorney(s) appearing for the Case
Harry C. Weeks, of Fort Worth, Tex., for petitioner.
Robert N. Anderson, Helen R. Carloss, and Maryhelen Wigle, Sp. Assts. to Atty. Gen., Sewall Key, Acting Asst. Atty. Gen., and J. P. Wenchel, Chief Counsel, Bureau of Internal Revenue, and Bernard D. Daniels, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., for respondent.
Before McCORD, WALLER, and LEE, Circuit Judges.
Circuit Court of Appeals, Fifth Circuit.
LEE, Circuit Judge.
When petitioner, a Delaware corporation,1 filed its income and excess profits tax return for the calendar year 1939, it deducted from gross income,2 as ordinary and necessary business expense, intangible costs incurred in the drilling and development of wells on certain leasehold properties in Texas as follows:3
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